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however, that the Preamble to the proposed regulation states that the proposed regulations
document IMAGES-009-HOUSE_OVERSIGHT_026591.txt House Oversight Committee — Epstein Estate Records (Nov 2025)

…rposes against income that may not be subject to U.S. tax. 7 In general, the DCL rules forbid a DRC from reducing the taxable income of any other member of its affiliated group by the amount of the DRE's DCL unless, as provided in the regulations, the loss does not offset the in...